Introduction

This statement sets out the Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2017 to 31 March 2018
It has been thoroughly reviewed and updated to reflect changes and positive developments over the past year and our intentions for the coming year.

The organisation is committed to preventing slavery and human trafficking in all its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

We will look forward to the coming year with a commitment to continue our activity to meet and exceed our legal and moral obligations under this legislation.

Our Vision and Values

Our shared vision is to have a positive impact on people and communities by providing high quality homes, supporting independence and creating opportunities.

Values we have that support this are that we are people-focused and we are genuine.

People are at the heart of our business. We look to treat everyone fairly and understanding their diverse needs. We are open and honest, with a friendly, enthusiastic and energetic way of working that is true to what we stand for.

Reflecting this in both our vision and values, we are pleased to be publishing our annual Modern Slavery and Human Trafficking Statement for this financial year.

Organisational structure

This statement covers the activities of the Group who own and manage approximately 11,000 homes. The Group operates mainly in Lancashire but provides Supported Living homes predominantly for people with a learning disability or mental health need nationwide, as well as accommodation for keyworkers in Lincolnshire. We also manage two women's refuges and three supported schemes for people facing homelessness. The Group also through Progress Lifeline provides telecare and technology enabled care and support services to nearly 23,000 telecare customers and supporting nearly 34,000 customers for all services provided under the Telecare Services, the Auditor recommends that Progress Lifeline is certified to the Quality Standards Framework.

Our range of housing includes general needs rented housing, supported living, supported housing, housing for older people, shared ownership, key worker accommodation and market-rented accommodation.

The Registered Provider (RP) companies consist of Progress Housing Group Limited (Parent) and Progress Housing Association Limited which includes our sub-brands. Progress Living and Progress Lifeline are part of Progress Housing Association Ltd, which is a charitable Registered Provider. Key Unlocking Futures Limited and Concert Living Limited are separate subsidiary companies of Progress Housing Group.

Our Supply Chain

The Group’s principal services are providing and developing social housing. Our Procurement Policy fully reflects what we do and what we require of our business partners (including assessment and procurement routes for development) to ensure full compliance with the Modern Slavery Act requirements. We ensure that any supplier or sub-contractor we work with goes through a comprehensive assessment process. We ask bidders as part of the procurement process what they do to ensure their own business and supply chain is free from modern slavery. Where this cannot be evidenced to the satisfaction of the Group, we would actively exclude from further involvement in a tender process.

Responsibility

The Executive Director, Finance and Corporate Services has strategic responsibility for the development and implementation of the Group’s anti-slavery initiatives and on-going review of our approaches. Key departments within the organisation such as Human Resources and Organisational Development, Procurement, Property Services, Development and Finance support the Executive Director in our operational responses.

Relevant Policies

The Group operates the following policies:

Code of Conduct – we strive to maintain the highest standards of employee conduct and ethical behaviour in delivering our services and managing our supply chain and the Group’s Code of Conduct clearly defines what is expected of our staff when representing the Group.

Recruitment and Employment – The Group will undertake all relevant pre-employment checks prior to staff being employed. Throughout the whole recruitment process and into the employment relationship, we pride ourselves on providing a safe environment, free from inequalities, where employees’ wellbeing is supported by responsible and inclusive employment practices.

We require our recruitment agencies to commit to the principles of fair and transparent recruitment processes in the provision of agency staff. We principally operate within an established framework agreement for the provision of recruitment services. Agency workers appointed are subject to a range of checks as a requirement of the framework. Should we appoint agency workers outside of the framework agreement, the providers are subject to the established due diligence required of all suppliers. In addition, we will carry out our own audits intended to identify, amongst other things, any Modern Slavery practices or gaps in right to work checks.

As an example of our commitment to fair employee treatment, the Group is committed to the Voluntary Living Wage promoted by the Living Wage Foundation.

Safeguarding – The Group will raise and maintain staff awareness of the risks of slavery and human trafficking through cyclical safeguarding training and briefing.

We remain committed to the highest standards of quality, probity, openness and accountability and as part of this commitment provide a confidential reporting process for employees to report serious concerns about any aspect of our work which includes abuse or neglect of vulnerable people.

Due Diligence

The Group has implemented (or will be implementing during this year), the following actions to mitigate the risk of slavery or human trafficking in the delivery of its services and supply chain:

  • All suppliers and contractors must be compliant with the legislation as a condition of business with the Group.
  • To ensure an understanding of the potential risks of modern slavery and human trafficking in delivering our services and managing our supply chain, we are providing training to relevant members of staff through classroom-based training. Our aim this year is to additionally introduce bespoke compulsory online training on Modern Slavery and Human Trafficking for key frontline staff to complete.
  • We will supplement training to staff providing active links and news items on our internal ‘Intranet’ staff pages, posters around the Group’s premises and all-staff emails to raise collective awareness. The collective aim of these is to highlight:
    • the basic principles of the Modern Slavery Act 2015;
    • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
    • what external help is available, for example through the Modern Slavery Helpline.
  • Where appropriate, we will include reference to the Modern Slavery and Human Trafficking Act 2015 in our policies and procedures and ensure our Safeguarding and Modern Slavery training to our staff gives guidance to staff on the identification and reporting of modern slavery or human trafficking.

Statement Approval

This statement has been approved by the Board of Progress Housing Group Limited who will ensure it is reviewed and updated annually.